Client Onboarding, KYC & FATCA Policy

This policy sets out how we onboard a new investor, what we verify before the first transaction is placed, and how we handle tax residency declarations. It applies to every investor serviced by PivotalFlow Financial.

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KYC Onboarding Process

RULES WE DO NOT BREAK

• No transaction is placed for an investor whose Know Your Customer formalities are not complete.

• No transaction is placed on an investor’s behalf without an instruction from that investor.

• No cash is accepted, and no payment is accepted in the name of the firm or of any employee. Every payment is made in favour of the concerned Asset Management Company.

• No signed blank form, cheque or transaction slip is accepted or retained.

• A one time password, folio password, net banking credential or debit card detail is never sought from an investor.

• The Employee Unique Identification Number of the person who canvassed the transaction is recorded on every application.
   

TAX RESIDENCY, RECORDS AND UPDATION

• Every investor gives a self-certification of tax residency under FATCA and the Common Reporting Standard at onboarding. A fresh certification is obtained whenever a change in circumstances affects the declaration.

• Where an investor is a non-resident, the applicable account type and the repatriation position are recorded on the folio.

• Where the investor is a minor, the guardian’s Know Your Customer records are obtained and the date of majority is tracked so that the folio is regularised on time.

• Records of identity, transactions and correspondence are preserved for the periods required by the Prevention of Money Laundering Act, 2002 and the rules made under it.

• Changes in address, mobile number, e-mail address, bank account, tax status or nomination are given effect only through the Asset Management Company or the Registrar, on your authenticated instruction.